The UK-headquartered company is expected to make tens of billions in profit from the sale but will only pay $5 billion in tax to the US authorities and nothing at all to the British tax authorities.

Vodafone is structuring the deal as a two-step transaction.

It will kick off the process via a pre-sale break-up of Vodafone Americas selling the non-Verizon assets that Vodafone wants to retain to another Vodafone company, as flagged by MoneyBeat on Friday.

In its statement Vodafone said that it would “undertake a rationalisation and reorganisation” so that the non-US assets of the US Group would be held outside the US in the future.

The holding company for Vodafone Americas, which is based in the Netherlands, will then sell the rump of the U.S. Group comprising the Verizon stake to Verizon Communications Inc..

“The sale of the U.S. Group is not taxable under standard U.S. and Dutch tax rules,” Vodafone said.

Vodafone may well decide to repatriate the sale proceeds in the U.K. taking advantage of U.K. tax legislation that exempts capital gains from the sales of shares to intermediary trading companies.

Neal Todd, a tax lawyer in the London office of Berwin Leighton Paisner, said that the Netherlands company could definitely transfer the proceeds from the sale to Vodafone PLC free of tax because of the exemption in the U.K. tax code.

This exemption was passed into law in 2002 under the auspices of then Treasury chief Gordon Brown. At the time of its introduction the government said it was designed “to ensure that important business decisions on corporate restructuring and reinvestment are made for commercial, rather than tax, reasons”.

A person familiar with the matter said the current Treasury chief George Osborne has no plans to change the exemption.

News of Vodafone’s expected small tax bill comes at a time of increased scrutiny of the taxes paid by multinational companies and wealthy individuals. The U.K. government, like many of its counterparts, is attempting to bring in additional revenue by cracking down on tax avoidance and evasion, and is also keenly aware of the heightened public resentment at the seemingly low taxes paid by some large firms and rich people during a time of austerity.

Margaret Hodge, the outspoken chair of Parliament’s public affairs committee that has been examining the tax affairs of multinational firms over the past year, told The Guardian newspaper that the U.K. tax authority, HM Revenue and Customs, should examine Vodafone’s tax arrangement at the earliest opportunity.

“HMRC must begin an absolutely thorough investigation to make sure that U.K. taxpayers receive the maximum to which they are entitled,” she said. “If there is a flaw in the law, it needs to be addressed by Treasury ministers urgently.”

The Treasury declined to comment on Ms. Hodge’s remarks, while an HMRC spokesman said it doesn’t comment on tax arrangements for individual companies, but said it ensures all businesses pay the tax due in accordance with U.K. tax law.

Mr. Todd said it was unfair to single Vodafone out for criticism over its tax bill.

“It [Vodafone] is using very specific exemptions in U.K. tax legislation that were designed to have this effect,” he said.

Vodafone has been at the sharp end of public criticism over the way in which it manages its group affairs to lower its U.K. tax for some years. For example, last June it was forced to justify its failure to pay corporation tax in 2011 when reports suggested the failure was linked its group financing operations in Luxembourg. It is also in the midst of a long running saga with India where it faces a retrospective tax bill of more than $2 billion on its first deal in India in 2007.

But there’s one group that’s likely to unabashedly cheer the company’s low tax bill: its shareholders, who are in line for a handsome pay-out of $84 billion, thanks in part to the tax arrangement.